ND-19-1006, Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item C.2.6.09.07 (Index Number 667)

Unit 4 - Notice of Uncompleted ITAAC 225-days Prior to Initial Fuel Load Item C.2.6.09.07 (Index Number 667)

ML19240B204
Person / Time
Site:	Vogtle
Issue date:	08/28/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-1006
Download: ML19240B204 (6)

Text

Michael J. Vox 7825 River Road Regulatory Affairs Director

^Southern Nuclear Vogtle 3 & 4 Waynesboro, GA 30830 706-848-6459 tel AU6 2 8 2019 Docket Nos.: 52-025 52-026 ND-19-1006 10CFR 52.99(c)(3)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Unit 3 and Unit 4 Notice of Uncompleted ITAAC 225-davs Prior to Initial Fuel Load Item C.2.6.09.07 [Index Number 6671 Ladies and Gentlemen:

Pursuant to 10 CFR 52.99(c)(3), Southern Nuclear Operating Company hereby notifies the NRC that as of August 23, 2019, Vogtle Electric Generating Plant(VEGP) Unit 3 and Unit 4 Uncompleted Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Item C.2.6.09.07

[Index Number 667] has not been completed greater than 225-days prior to initial fuel load. The Enclosure describes the plan for completing this ITAAC. Southern Nuclear Operating Company will, at a later date, provide additional notifications for ITAAC that have not been completed 225-days prior to initial fuel load.

This notification is informed by the guidance described in NEI 08-01, Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52, which was endorsed by the NRC in Regulatory Guide 1.215. In accordance with NEI 08-01, this notification includes ITAAC for which required inspections, tests, or analyses have not been performed or have been only partially completed. All ITAAC will be fully completed and all Section 52.99(c)(1) ITAAC Closure Notifications will be submitted to NRC to support the Commission finding that all acceptance criteria are met prior to plant operation, as required by 10 CFR 52.103(g).

This letter contains no new NRC regulatory commitments.

If there are any questions, please contact Tom Petrak at 706-848-1575.

Respectfully submitted,

\/lichael J. Vox Regulatory Affairs Director Vogtle 3 & 4

Enclosure:

Vogtle Electric Generating Plant(VEGP) Unit 3 & Unit 4 Completion Plan for Uncompleted ITAAC C.2.6.09.07[Index Number 667]

MJY/RLB/sfr

U.S. Nuclear Regulatory Commission ND-19-1006 Page 2 of 3 To:

Southern Nuclear Operating Company/ Georgia Power Company Mr. P. P. Sena III (w/o enclosures)

Mr. D. L. McKinney(w/o enclosures)

Mr. M. D. Meier(w/o enclosures)

Mr. D. H. Jones(w/o enclosures)

Mr. G. Chick Mr. M. J. Yox Mr. A. S. Parton Ms. K. A. Roberts Mr. T. G. Petrak Mr. C. T. Defnall Mr. C. E. Morrow Mr. J. L. Hughes Ms. K. M. Stacy Ms. A. C. Chamberlain Mr. J. C. Haswell Document Services RTYPE: VND.LI.L06 File AR.01.02.06 cc:

Nuclear Reoulatorv Commission Mr. W. Jones(w/o enclosures)

Mr. F. D. Brown Mr. C. P. Patel Mr. G. J. Khouri Ms. S. E. Temple Mr. N. D. Karlovich Mr. A. Lerch Mr. C. J. Even Mr. B. J. Kemker Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic Mr. V. Hall Mr. G. Armstrong Ms. T. Lamb Mr. M. Webb Mr. T. Fredette Mr. C. Weber Qqlethorpe Power Corporation Mr. R. B. Brinkman Mr. E. Rasmussen Municipal Electric Authority of Georoia Mr. J. E. Fuller Mr. S. M. Jackson

U.S. Nuclear Regulatory Commission ND-19-1006 Page 3 of 3 Dalton Utilities Mr. T. Bundros Westinahouse Electric Company. LLC Dr. L. Oriani (w/o enclosures)

Mr. D. 0. Durham (w/o enclosures)

Mr. M. M. Corletti Ms. L. G. I Her Mr. Z. 8. Harper Mr. J. L. Coward Other Mr. J. E. Hesler, Bechtel Power Corporation Ms. L. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, inc.

Mr. 8. Roetger, Georgia Public Service Commission Ms. 8. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Baich Bingham

U.S. Nuclear Regulatory Commission ND-19-1006 Enclosure Page 1 of 3 Southern Nuclear Operating Company ND-19-1006 Enclosure Vogtle Electric Generating Plant(VEGP)Unit 3& Unit 4 Completion Plan for Uncompleted ITAAC C.2.6.09.07[Index Number 667]

U.S. Nuclear Regulatory Commission ND-19-1006 Enclosure Page 2 of 3 ITAAC Statement Desion Commitment

7. Access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

7.a) Vital equipment is located only within a vital area.

7.b) Access to vital equipment requires passage through the vital area barrier.

Inspections/Tests/Analvses Inspection will be performed to confirm that access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

Inspection will be performed to confirm that vital equipment is located within a vital area.

Inspection will be performed to confirm that access to vital equipment requires passage through the vital area barrier.

Acceptance Criteria Vital equipment is located within a protected area such that access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

All vital equipment is located only within a vital area.

Vital equipment is located within a protected area such that access to vital equipment requires passage through the vital area barrier.

ITAAC Completion Description Inspections are performed to verify that access to vital equipment physical barriers requires passage through the protected area perimeter barrier, vital equipment is located only within a vital area, and access to vital equipment requires passage through the vital area barrier. The inspections confirm that the applicable vital equipment location requirements of the VEGP Units 3 and 4 Physical Security Plan associated with 10 CFR 73.55(e)(9)(i) are satisfied. The VEGP Unit 3(Unit 4) Plant Security System ITAACs only cover the Unit 3(Unit 4) plant security system design commitment scope. The Unit 3(Unit 4) list of vital equipment is based on the API000 standard design vital equipment list (Reference 1), as modified by the site-specific Vogtle Unit 3

& 4 Vital Equipment List(Reference 2). The Unit 3(Unit 4) vital areas are identified in the VEGP Units 3 and 4 Physical Security Plan (Reference 3).

Vital equipment is located within a protected area such that access to vital eauioment ohvsical barriers reouires oassaoe through the protected area oerimeter barrier.

An inspection is performed per Procedure XXX (Reference 4)to confirm that access to the Unit 3(Unit 4) vital equipment located in vital equipment physical barriers requires passage through the Unit 3(Unit 4) protected area perimeter barrier. The inspection uses the Vogtle Unit 3 & 4 Vital Equipment List, VEGP Units 3 and 4 Physical Security Plan vital area listing, approved construction drawings, and performance of walkdowns to validate that access to vital equipment located in vital equipment physical barriers (vital area barriers) requires passage through the protected area perimeter barrier. The inspection confirms that access to the vital equipment

U.S. Nuclear Regulatory Commission ND-19-1006 Enclosure Page 3 of 3 Identified In Reference 2 requires passage tfirougfi at least two phiyslcal barriers, I.e., the protected area barrier and a vital area barrier.

The Inspection results are documented In Reference 4 and verify that the Unit 3(Unit 4) vital equipment Is located within a protected area such that access to vital equipment physical barriers requires passage through the protected area perimeter barrier.

All vital eouloment Is located onlv within a vital area.

An Inspection Is performed per Procedure XXX (Reference 4)to confirm that all Unit 3(Unit 4) vital equipment Is located only within a Unit 3(Unit 4) vital area. The Inspection uses the Vogtle Unit 3 & 4 Vital Equipment List, VEGP Units 3 and 4 Physical Security Plan vital area listing, approved construction drawings, and performance of walkdowns to validate that all vital equipment Is located only within a vital area.

The Inspection results are documented In Reference 4 and verify that all Unit 3(Unit 4) vital equipment Is located only within a vital area.

Vital equipment Is located within a protected area such that access to vital eouloment requires passage throuoh the vital area barrier.

An Inspection Is performed per Procedure XXX (Reference 4)to confirm that all Unit 3(Unit 4) vital equipment Is located within a Unit 3(Unit 4) protected area such that access to vital equipment requires passage through the vital area barrier. The Inspection uses the Vogtle Unit 3 & 4 Vital Equipment List, VEGP Units 3 and 4 Physical Security Plan vital area listing, approved construction drawings, and performance of walkdowns to validate that vital equipment Is located within a protected area such that access to vital equipment requires passage through a vital area barrier.

The Inspection results are documented In Reference 4 and verify that Unit 3(Unit 4) vital equipment Is located within a protected area such that access to vital equipment requires passage through the vital area barrier.

Reference 4 Is available for NRC Inspection as part of the Unit 3(Unit 4) ITAAC C.2.6.09.07 Completion Package(Reference 5[6]).

List of ITAAC Findings In accordance with plant procedures for ITAAC completion. Southern Nuclear Operating Company(SNC) performed a review of all findings pertaining to the subject ITAAC and associated corrective actions. This review found there are no relevant ITAAC findings associated with this ITAAC.

References ^available for NRC inspection)

1. APP-SES-M3C-001, Vital Equipment List(SGI)

2. Vogtle Unit 3 & 4 Vital Equipment List(SGI)

3. VEGP Units 3 and 4 Physical Security Plan (SGI)

4. Procedure XXX, Unit 3(Unit 4) Vital Equipment Location and Access Inspection

5. C.2.6.09.07-U3-CP-Rev0, ITAAC Completion Package

6. C.2.6.09.07-U4-CP-Rev0, ITAAC Completion Package

7. NEI 08-01,"Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52"